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SA Construction Industry OHS Committee
- SA CIOC -
RESPONSE TO SAFEWORK AUSTRALIA REGARDING THE CODE OF PRACTICE FOR SAFE
DESIGN OF BUILDING AND STRUCTURES
The Construction Industry Standing Committee for Occupation and Health and Safety for South
Australia presents these comments in relation to the Code of Practice for Safe Design of Buildings and Structures. The following are areas of concern that the Committee wishes to have considered in the review of the Code, prior to its final release.
Scope and Application
The Committee feels that an explicit statement is required in this Section removing the need to provide a written report relating to health and safety risks for projects under $250,000. Noting that it is likely that this dollar value will capture most owner/builders, it is proposed that the requirement for a designer to provide a written report relating to health and safety risks be excluded.
While not underestimating that risks are still inherent in smaller construction, never-the-less the
Committee is of the view that practically the cost of involving a designer and therefore the preparation of a design report is an additional impost that will add little or no value to projects at this scale.
Section 1.3 Other persons with key roles in design and construction
The Committee feels that there is a lack of emphasis relating to operation, maintenance and demolition. This is proposed to be addressed in two ways.
Firstly, this could be included in “The Client” role, where an assumption is made that the client continues through the life of the building, however this would need to have careful wording to ensure that the responsibilities transfer to an owner in the situation of a developer client who subsequently disposes of the building.
To this end Client obligations have not been emphasised enough, in their role as commissioners of design work. Designers have an obligation to consider the whole life cycle of a building or structure; they are also often restricted by budgets established by the Client. An example could be provided in the Code, with regard to the handover from client/developer/commissioning contractor etc, to emphasise the obligations of future owners in relation to design for demolition and disposal, or modifications to buildings and structures.
A second, and preferable alternative would be to introduce a further key role; that of
Owner/Operator, focussing on design obligations. This class of person would assume responsibilities as outlined above, including ultimate demolition and disposal of the building.
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Though a Client may intend disposing of the building after initial construction, the identification of obligations for the role of owner and operator, with regard to the building design, would alert them to the need to have these obligations in mind as they commission a designer to carry out the work.
This class of person would also have responsibilities for establishing and maintaining building records, the design report and any other operational or maintenance manuals.
As corollary, the Committee believes that once this aspect has been addressed, it should also be carried into Appendix A - Roles and Responsibilities and the responsibilities of the Client expanded to include these additional responsibilities as well.
Section 4 Design Considerations for Construction, Use and Maintenance
The Committee feels that this section would be considerably strengthened by examples that extend into different aspects of the construction industry. For example, it is understood that infrastructure projects, including roads, bridges, ports and rail, are covered by the Scope outlined earlier. To this end, examples that demonstrate this breadth of application would enhance the use of the Code.
Other matters of importance
The Committee notes that there is a substantial lack in coverage of plant design and operation.
However we understand that there is a commitment to prepare a specific Code of Practice covering this matter, which we feel is an essential addition to the suite of documents associated with the new Act.
In other regards the Committee feels that the Code is a useful and useable document, although a one-page users guide would be a useful addition.
Jerome Argue
Chairperson
Task Force – Code of Practice for Safe Design of Building and Structures
SA Construction Industry OHS Committee
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